1. SECTION 325(C) OF THE EMERGENCY PLANNING AND COMMUNITY RIGHT-TO-KNOW ACT OF 1986 ( EPCRTKA ), 42 U.S.C. SECTION 11045(C). 2. INDUSTRIAL METAL FINISHING COMPANY 4200 PERRY HOUSTON, TEXAS 77022 3. RESPONDENT WAS IN VIOLATION OF SECTION 313(A) OF EPCRA BY FAILING TO SUBMIT TIMELY, COMPLETE, AND CORRECT TOXIC CHEMICAL RELEASE INVENTORY REPORTING FORMS ( FORM R ) FOR CYANIDE COMPOUNDS FOR THE YEAR 1988, HYDROCHLORIC ACID FOR THE YEARS 1989 AND 1990. 4. RELIEF SOUGHT PURSUANT TO SECTION 325(C) OF EPCRA, EPA PROPOSES A CIVIL PENALTY OF $15,000 ($5,000 PER VIOLA- TION).